Privacy Notice for Participants in Surveys

This privacy notice describes how FOTP Research Limited (“we” or “us“) uses personal data relating to participants in our surveys as part of research programmes within the UK (referred to as “you“).

We may update this notice from time to time. It was last updated on the 30th March 2020.

This notice is set out in the following sections:

Who we are

What data we collect and how we use it

Sharing your information and our relationship with other parties

Consents and legal basis for use of your data

International data transfers

Retaining your information

Security of your data

Your rights, including your right to access a copy of the data we hold

Our contact details

1. WHO WE ARE

FOTP Research Limited is a company registered in England and Wales with company number 06269669. We conduct market research programmes within the UK.

We conduct these programmes on behalf of UK clients, both suppliers and other traders, focussing on the automotive, defence, logistics and agribusiness industries. Your involvement in our surveys enables these organisations to give and receive feedback from their key stakeholder groups with whom they work, and assists them to understand and improve their performance. These stakeholder groups are predominantly employees, customers and suppliers.

We act as a ‘controller’ for the purposes of data protection laws in our use of your data for these programmes. This means that we will determine how and why your data is collected and used, and we do not share your individual survey feedback, either quantitative or qualitative (in a form which identifies you) with our clients. Our approaches for sharing survey data with clients are described at section 3.2 below.

You may contact us with any queries or concerns about our use of your data, and to exercise your data protection rights (see section 7 below). Our contact details are set out at section 8 below.

2. WHAT DATA WE COLLECT AND HOW WE USE IT

2.1.Initial communication about a research programme

Your name, the company you work for, your role and your contact details may be provided to us by organisations who have suggested that we obtain your feedback as part of one or more research programmes. These organisations may be either:

the organisation for whom you work (i.e. your employer); or

an organisation with whom you have had contact as part of your role, for example supplier organisations provide us with details of their contacts at their customer organisations or vice versa.

If you would like to know the specific source of your contact details, please ask us using the contact details at section 8 below.

We use these details to send you an initial email or other communication about the specific programme and the survey we are undertaking, and to request your participation. It is voluntary to participate in this survey.

We may also retain your contact details for use in the following year’s programme (unless you request us not to use them for this purpose).

2.2. Survey responses

Our initial communication may send you a link to an online questionnaire, or otherwise describe how you may participate in the survey. It is voluntary to participate, but if you decide to do so, you are indicating your consent to us using your responses in the way described in this notice.

We will initially ask you to confirm some business information, including:

your name, telephone number and email address, which we will use to contact you in relation to the survey; and

your job title and your company, which we use to check that you are an appropriate participant for the survey and to aggregate your data into the appropriate respondent group.

We then ask you a series of more specific research questions aimed at providing feedback to your commercial partners. These may include, for example, your assessment of the quality of your business relationships and people you deal with.

We may follow up with an email and/or telephone interview to discuss your responses in more detail. (subject to obtaining your consent). Telephone calls may be recorded so that we can make an accurate record of your qualitative feedback. The recording is destroyed within six months.

Your ratings are then analysed, and aggregated results of the surveys are reported to our clients and related organisations. Scores are anonymised, and we take reasonable precautions to ensure you are not identifiable from your comments, which will not be attributed to you as an individual.

You should not ordinarily provide information which identifies another individual as part of your survey responses. However, if you do provide any information about another individual (such as a specific person within the organisation about whom you are providing feedback), please inform that other individual that you are doing so. In addition, the feedback provided by you should be yours only and those of your colleagues. You should inform your colleagues if you are providing feedback on their behalf.

2.3. Other

Your personal data may also be used by us as follows:

to maintain appropriate records of our business communications and transactions. For example, if you contact us to discuss the survey or our use of your data, we will retain a record of the communications between you and us;

to protect or enforce legal rights, or for other purposes permitted or required by law (including data protection law);

we may contact you to share with you any aggregated data from the programme relevant to your responses.

we may contact you to understand your interest in joining the programme. You may request at any stage that we do not send you these types of communications.

2.4. Sensitive personal data

We do not currently collect sensitive categories of data as part of our surveys (for example, information about health, racial or ethnic origin, or criminal convictions). If any such data becomes relevant as part of any research programme, we will seek to provide you with more information about this at the time.

3. SHARING YOUR DATA AND OUR RELATIONSHIP WITH OTHER PARTIES

3.1. Qualtrics

We use Qualtrics software to design online questionnaires and collect quantitative feedback from you.

In addition, we use Qualtrics software to process and aggregate your individual quantitative feedback received as part of the research projects.

Qualtrics treats all Customer Data as highly confidential. All Customer Data is safeguarded using industry-best security practices to prevent unlawful disclosure. Qualtrics does not sell or make available Customer Data except as requested by a valid court order, search warrant, subpoena, or otherwise as agreed by the parties or required by law.

Qualtrics complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU), the United Kingdom, and Switzerland to the United States, respectively, including the onward transfer liability provisions. Qualtrics has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

3.2. Clients and related organisations

Aggregated results of surveys (using information from your responses) will be used to provide feedback to our clients and organisations with whom they work. Aggregated results will mainly be used by our clients to identify opportunities for improvement, develop action plans and trend performance over time, in case the projects are repeated. See also section 2.2 above. The results are aggregated as follows.

Scenario 1 – Feedback from traders to suppliers

Your individual ratings are aggregated with others from your company before any quantitative data is released to clients. Your qualitative feedback is edited and only identified by company name.

Your individual ratings are aggregated with those of other participating suppliers, employees or customers. Your qualitative feedback is edited and aggregated with the comments from other participating suppliers, employees or customers . It is not identified by company or individual.

3.3. Our technology service providers

Our technology service providers may also handle your data, such as our e-mail provider (currently Microsoft Office 365), or the provider of our survey software (currently Qualtrics). They act as processors on our behalf, meaning that we remain primarily responsible for how they use your data.

We may also share your data with the following parties:

legal authorities or regulatory bodies;

our legal or other professional advisers, insurers and auditors;

prospective or actual purchasers of our company or business; and

other parties to the extent you have consented to us doing so, or where we are otherwise required or permitted by law to do so.

4. CONSENTS AND LEGAL BASIS FOR USE OF YOUR DATA

In accordance with data protection laws, we have identified the legal basis for the collection, use and disclosure of your data, as described above. The following apply to our activities.

4.1. Consents

We seek the following consent from you to our use of your personal data.

Consent to use of your survey responses (including questionnaire and interview feedback) for the purposes of the relevant research programme. Your participation in the survey and submission of your questionnaire responses rely on you consenting to this. See section 2.

Consent to the recording of telephone interviews. See section 2.

You may withdraw any consent you have given at any time – see section 7 below.

4.2. Legitimate interests

We collect, use and retain personal data (including your contact details and communications with you) which is necessary for our legitimate interests in running the research programmes and in the operation of our business, for example to request your participation in surveys, manage and administer our relationship with you and our clients, maintain records of communications, and protect our legal rights and those of others.

We may also retain your contact details for use in relation to the following year’s programme, unless you indicate to us that you do not wish us to do so.

4.3. Legal obligation

We may collect, use or disclose personal data as is necessary to comply with a legal obligation, such as where law enforcement authorities require us to do so or to address rights of other individuals under data protection laws.

5. INTERNATIONAL DATA TRANSFERS

FOTP Research Ltd and our activities are based in the UK. [However, some of our technology systems provided by third parties on our behalf are located in countries outside the European Union, where the laws may not provide the same level of protection for personal data as under UK or European Union law. We do, however, check that safeguards are in place to protect your data to a similar standard as under UK law.

6. RETAINING YOUR INFORMATION

We will retain your personal data for as long as we need it for the relevant purposes specified above, in accordance with our records retention procedures.

We will retain your original responses to our surveys in an identifiable format for a period of two years for the purposes of quality control and to address any queries arising. Aggregated Information obtained from them and forming part of our survey analysis and reports may be retained beyond this. These are used for research and statistical purposes, including to identify trends and developments within the research programmes. Note that our reports containing aggregated data are also shared with our clients and other third parties, who may also retain copies.

Telephone recordings are destroyed within six months.

We may also continue to maintain records relating to you (such as communications with you) for our own record-keeping purposes, including to comply with our legal obligations and to defend our legal rights.

7. YOUR RIGHTS

If you do not wish us to retain your details to contact you with further surveys, please let us know. Please note that, even if you request this, you may hear from us again if your employer, or parties with whom you work, provide us with your contact details again.

Note that our research surveys would not ordinarily be considered as direct marketing, so if you have previously opted out of direct marketing communications, you may still hear from us in relation to our surveys.

In accordance with data protection laws, you also have a right:

to obtain a copy of the personal data we hold about you, together with other information about how we process it. This includes your questionnaire responses and a transcript of any telephone interview;

to withdraw any consent which you have given relating to use of your data (see section 1);

to request rectification of inaccurate or incomplete data, and, in some circumstances, to request us to erase or restrict our use of your data, or otherwise to object to our processing of your data for direct marketing purposes or for reasons relating to your particular situation;

to receive a copy (in a machine-readable format) of personal data which you have provided to us, to the extent we process it electronically based on your consent (see section 4 above);

not to be subject to a decision based solely on automated processing, which significantly affects you (though, as at the date of this notice, we do not make any such automated decisions about you); and

to make a complaint about how we handle your data to the UK Information Commissioner’s Office. Please visit ico.org.uk for further information about how to do this.

Note that there are certain limitations and exemptions to these rights which we may apply depending on the circumstances.

If you request erasure of your survey data (for example following withdrawal of your consent to us using it), note that information obtained from your responses may still form part of aggregated and anonymised data sets which have already been collated, used and disclosed for the purposes of the research programme.

Please contact us (see section 8 below) to send us requests to exercise these rights (specifying what you are requesting), or if you would like further information about them.